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HMRC internal manual

Guidance on Real Estate Investment Trusts

HM Revenue & Customs
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Entry to the regime: effects of entry: other expenses etc pre-entry periods

The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See GREIT03100 for descriptions of terms used below.

Table 3: other expenses, losses etc

Description Type of loss etc Can be used against
Losses brought forward against certain investment income section 393(8) ICTA Same type of investment income included in the residual business
Unused non-trading loan relationship and derivative contract deficits section 457 CTA 2009 (financial instruments) Non-trading profits included in the residual business (even if deficit relates to financing costs etc of qualifying property business carried on pre-entry)
CVS loss relief Section 573 ICTA Investment companies only
Excess management expenses Section 1223 CTA 2009 Profits of the residual business (even if excess related to managing subsidiaries that operated qualifying property business pre-entry)
CAs for management of business   Investment companies only
Unused non-trading losses on intangible fixed assets Paragraph 35(3) Schedule 29 FA 2002. Future profits of the residual business
Non-trade CAs   Future profits of the residual business
Excess charges paid Section 338(4) ICTA No carry forward (relief restricted to payments made in the accounting period)



See GREIT03100 and GREIT03105 for Tables 1 and 2: capital and trading losses etc.